Public documents
Four foundational policies, published in full. Schools may request signed copies and our certificates of insurance for their files at schools@thepeloteacademy.org.
Adopted: [date] · Approved by: Board of Directors · Review cycle: Annually, and after any incident
Applies to: All employees, volunteers, contractors, interns, and board members
These four policies must be adopted before a single student is served. No school will sign an MOU without them and no insurer will bind coverage without them.
Written for the supportive-services model. Nothing here authorizes clinical mental health treatment.
To prevent harm to the children in our care, to remove any ambiguity about what adult conduct is acceptable, and to make violations easy to identify and act on.
Every employee, volunteer, contractor, intern, and board member. There are no exceptions for seniority, tenure, relationship to leadership, or family connection to a student.
No adult is ever alone and unobserved with a student.
Every adult signs this policy at onboarding and annually thereafter. The signed copy is kept in their personnel file. Refusal to sign ends the assignment.
To ensure that no adult has contact with a student before their history has been checked, and to keep those checks current.
| Check | Agency | How | Cost |
|---|---|---|---|
| State + FBI criminal history, fingerprint-based | Maryland CJIS Central Repository (DPSCS) | Livescan at an approved provider | Varies by provider |
| Child Protective Services clearance | Maryland DHS / local DSS | Agency request | Varies |
| National Sex Offender Public Website | NSOPW.gov | Free search, printed and filed | Free |
| Out-of-state criminal check | Applicable state | Required for any state of residence in the past 5 years | Varies |
Action required first: The academy must register with CJIS as an authorized agency to receive criminal background information and obtain an authorization number. There is no fee to become an authorized agency. Contact CJIS Customer Service at 410-764-4501 or 1-888-795-0011, Monday–Friday, 8:00 a.m.–5:00 p.m. Without an authorization number you cannot lawfully receive results.
In-state applicant fingerprints must be submitted electronically by approved Livescan. Ink fingerprint cards are accepted only for a documented medical reason.
| Check | Agency | How | Cost |
|---|---|---|---|
| Central Registry search (founded child abuse/neglect) | VDSS Office of Background Investigations | OBI web portal, or Central Registry Release of Information Form by mail | ~$12 online / $10 by mail |
| Fingerprint-based criminal history | VDSS-OBI via Fieldprint | Register for a Fieldprint appointment through the OBI portal | Varies |
| Sworn Disclosure Statement | Internal | Signed by applicant before hire | Free |
| National Sex Offender Public Website | NSOPW.gov | Free search, printed and filed | Free |
OBI contact: backgrounds@dss.virginia.gov. Mailed Central Registry forms require original signatures and payment by money order, business check, or cashier's check — personal checks and cash are not accepted.
Barrier crimes. Virginia law bars individuals convicted of specified offenses from working with children. The Sworn Disclosure Statement and the criminal record check together establish eligibility.
Provisional hire. Virginia permits provisional assignment once fingerprint results have returned qualifying, a Sworn Disclosure is signed, the Central Registry check has been requested, and the person is supervised at all times by a fully cleared adult. The Pelote Academy does not use provisional hire for its first two years. No one has student contact until every check has returned clear.
Two professional references, contacted by phone, not email, with notes recorded in the file. At least one must be a former supervisor. References are checked before an offer is extended, not after.
No step is skipped and no step happens out of order.
Screening results are confidential, stored in a locked file or an access-controlled digital folder, and released only to a partner school's designated compliance officer on written request. Results are not transferable between organizations.
Any founded finding of child abuse or neglect, any conviction for a crime against a child, any sexual offense, and any violent felony are permanently disqualifying. Other history is reviewed case by case by the Program Director and Board Chair, with the written determination kept in the file.
Everyone at The Pelote Academy is a mandated reporter, whether or not state law classifies their specific role that way. We hold ourselves to the higher standard by policy.
Suspicion is the threshold, not proof. You do not need evidence. You do not need to be right. You need a reasonable suspicion.
You may report anonymously. We advise against it. An anonymous report leaves no record that you met your legal obligation and no way for CPS to follow up with you. Give your name.
Reporters who act in good faith are protected from legal action under both Maryland and Virginia law. Retaliation against a reporter by anyone at The Pelote Academy is grounds for immediate termination and is reported to the board.
Mandated reporter training is completed at onboarding and refreshed annually. Both Maryland and Virginia offer free online training through their social services agencies. Completion certificates are kept in the personnel file.
The hotline numbers in Section 2 are posted at every program site, in the staff area and by every phone, in type large enough to read from across the room.
The Pelote Academy provides supportive mental wellness services. We do not provide clinical mental health treatment.
What we do: - Teach stress management, focus, and self-regulation skills - Run group sessions on handling pressure, conflict, and disappointment - Conduct regular one-on-one wellness check-ins as part of mentorship - Notice when a student is struggling and connect the family to licensed care - Give families practical help navigating the referral and insurance process
What we do not do: - Diagnose any mental health condition - Provide therapy, counseling, or psychotherapy - Recommend, prescribe, or advise on medication - Provide crisis clinical intervention beyond first response and connection to emergency services - Represent any staff member as a therapist, counselor, or clinician unless they hold a current license and are contracted in that capacity
This scope statement appears on our website, in our enrollment packet, and in every school MOU. Staff state it plainly to any family who asks for more than we provide.
When to refer: persistent changes in mood, sleep, appetite, or engagement; withdrawal from activities the student used to enjoy; any expression of hopelessness; any self-harm; substance use; a disclosure of trauma; or a request for help from the student or family.
How a referral happens: 1. Staff member raises the concern with the Site Coordinator the same day. 2. Site Coordinator and Program Director review and decide whether to refer. 3. Program Director contacts the parent or guardian directly — never a note home, never a text. 4. The family is offered the referral list and practical help making the first call. 5. Follow-up contact at two weeks. Documented. 6. The family decides. We do not require a family to seek care as a condition of participation.
Build and maintain this referral list before you open: - The student's school counselor and school psychologist — always the first call for an enrolled student - Local community behavioral health clinics and federally qualified health centers - Maryland: 211 Maryland, which maintains a searchable behavioral health directory - Providers accepting Medicaid, which matters more than any other filter for the families you will serve - Sliding-scale and no-cost providers - Culturally matched providers, which families ask for and rarely get offered
Review and update the list every six months. A referral list with dead phone numbers is worse than none.
If a student discloses suicidal thoughts, self-harm, abuse, or an immediate safety threat:
988 is posted at every site and printed on every student ID card.
Students are told at intake, in plain language:
"What you tell your mentor stays between you and your mentor, with three exceptions: if someone is hurting you, if you're thinking about hurting yourself, or if you're thinking about hurting someone else. In those cases I have to tell someone who can help keep you safe. I'll tell you when I do it."
This is repeated, not stated once and filed away.
Staff who respond to a crisis, receive a disclosure, or file a CPS report are offered a debrief and, where available, employee assistance resources. Secondary trauma is real and the academy treats it as an operational risk, not a personal weakness.
This policy is reviewed annually and after every crisis event. If the academy later decides to add clinical services, this policy is replaced — not amended — and the change requires board approval, licensed clinical staff, malpractice coverage, and revised MOU language.
| Policy | Drafted | Board approved | Effective | Next review |
|---|---|---|---|---|
| P-01 Child Protection & Safeguarding | ||||
| P-02 Background Screening & Onboarding | ||||
| P-03 Mandated Reporting | ||||
| P-17 Mental Wellness, Scope & Referral |
Before adopting: have a Maryland nonprofit attorney review P-01, P-02, and P-03. Maryland Nonprofits maintains a legal referral service and offers member pricing. This is the one place in the whole build where paying for an hour of legal review is not optional.